Privacy Statement

Table of Contents

• Introduction
• Data Protection Officer
• How we collect and use (process) your personal information
• Use of the Axe Payments Limited Website
• Cookies and tracking technologies
• Sharing information with third parties
• International transfers of personal data
• Data Subject rights
• Security of your information
• Data storage and retention
• Questions, concerns, or complaints

Introduction

Axe Payments Limited is a Limited Company. We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Privacy Notice describes the Axe Payments Limited's policies and practices regarding its collection and use of your personal data, and sets forth your privacy rights. We recognise that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies.

Data Protection Officer

Axe Payments Limited is headquartered in Dublin, Ireland, in the European Union. Axe Payments Limited has appointed an internal data protection officer for you to contact if you have any questions or concerns about Axe Payments Limited's personal data policies or practices. If you would like to exercise your privacy rights, please direct your query to Axe Payments Limited's data protection officer. Axe Payments Limited's data protection officer's name and contact information are as follows:

How we collect and use (process) your personal information

Axe Payments Limited collects personal information about its website visitors and customers in three ways:

1. Information you provide directly

When you register, contact us, or request a demo, you may provide us with the following personal information:

• name
• email
• job title
• employer name
• work address
• work phone number

We use this information to provide prospects and customers with services. We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of our services.

2. Information collected automatically

When you visit our website, we automatically collect certain technical and behavioural data through cookies and third-party analytics tools. This includes IP addresses, browser type, operating system, referring URLs, pages visited, and approximate geographic location. This data is collected via the following tools, each of which may transfer data to servers in the United States:

• Google Analytics 4: collects aggregated data on visitor behaviour including pages visited, session duration, and device type. Data is processed by Google in the United States under Standard Contractual Clauses.
• Hotjar: records session behaviour including clicks, scrolls, and navigation patterns to help us improve the user experience. Hotjar masks user input fields by default. Data is processed by Hotjar Ltd under Standard Contractual Clauses.
• Datadog Real User Monitoring: monitors website performance, page load times, and browser errors. User input fields are masked. Data is processed by Datadog Inc. in the United States under Standard Contractual Clauses.
• Google reCAPTCHA v3: runs on all pages to distinguish human visitors from automated bots. It collects hardware and software information including device and application data and sends it to Google. This operates in the background without any visible challenge to the user. Data is processed by Google in the United States under Standard Contractual Clauses.

3. Information received from third parties

From time to time, Axe Payments Limited receives personal information about individuals from third parties. Typically, information collected from third parties will include further details on your employer or industry. We may also collect your personal data from third party websites for sales and outreach purposes.

Legal bases for processing (GDPR Article 6)

The table below sets out the legal basis under Article 6 GDPR that we rely on for each category of processing:

Use of the Axe Payments Limited Website

As is true of most other websites, Axe Payments Limited's website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of Axe Payments Limited's website, including a history of the pages you view. We use this information to help us design our site to better suit our users' needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyse trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences. This data is collected using the third-party tools described in the “How we collect and use your personal information” section above, and in our full Cookie Policy at https://www.joinaxe.ai/cookies.

Axe Payments Limited has a legitimate interest in understanding how customers and potential customers use its website. This assists Axe Payments Limited with providing more relevant products and services and improving the performance and reliability of our website.

Cookies and tracking technologies

Axe Payments Limited uses cookies and similar tracking technologies on its website. Under the ePrivacy Directive as implemented in Irish law, non-essential cookies may only be placed with your prior consent. When you first visit our website, a cookie consent banner will ask for your consent before any non-essential cookies are set. You may withdraw or change your consent at any time through the cookie settings link in our website footer.

We classify our cookies as follows: Google Analytics 4, Hotjar, and Datadog Real User Monitoring are non-essential cookies requiring your consent. They will only be loaded if you accept analytics cookies via the banner. Google reCAPTCHA v3 is used for website security and operates on the basis of legitimate interest; it runs in the background on all pages to distinguish human visitors from automated bots without requiring a visible challenge. For full details of every cookie set, its purpose, provider, and duration, please see our Cookie Policy at https://www.joinaxe.ai/cookies. You can also control cookies through your browser settings, though disabling certain cookies may affect website functionality.

Sharing information with third parties

The personal information Axe Payments Limited collects from you is stored in one or more databases hosted by third-party service providers. These third parties are located primarily within the European Economic Area; where located outside the EEA, appropriate safeguards are in place as described in the “International transfers of personal data” section below. Our third-party providers fall into two categories: infrastructure and storage providers (such as cloud hosting and database services) act solely as data processors under our instructions, and do not use your personal information for their own purposes. Analytics, monitoring, and security tools (including Google Analytics, Hotjar, and Datadog) may act as independent data controllers or joint controllers for their own purposes, such as product improvement and fraud prevention; their processing is governed by their own privacy policies. On occasion, Axe Payments Limited engages third parties to send information to you, including information about our products, services, and events.

A list of our third party sub processors can be found here: https://www.joinaxe.ai/compliance/subprocessors

We do not otherwise reveal your personal data to non-Axe Payments Limited persons or businesses for their independent use unless: (1) you request or authorise it; (2) it's in connection with Axe Payments Limited-hosted and Axe Payments Limited co-sponsored conferences or events; (3) the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (5) to address emergencies or acts of God; or (6) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.

International transfers of personal data

Axe Payments Limited is headquartered in Dublin, Ireland, and your personal data is primarily processed within the European Economic Area (EEA). As an Irish-registered company, Axe Payments Limited is subject to the General Data Protection Regulation (GDPR) as applied in Ireland, and is supervised by the Irish Data Protection Commission (DPC) as its lead supervisory authority.

Some of our third-party service providers and sub-processors are located outside the EEA, including in the United States. Where personal data is transferred to a country that has not been granted an adequacy decision by the European Commission under Article 45 of the GDPR, Axe Payments Limited ensures that appropriate safeguards are in place pursuant to Article 46 of the GDPR. These safeguards include the use of Standard Contractual Clauses (SCCs) approved by the European Commission, supplemented where necessary by additional technical and organisational measures in accordance with guidance from the European Data Protection Board. A list of our sub-processors, including their locations, is available at https://www.joinaxe.ai/compliance/subprocessors.

For more information or if you have any questions about international data transfers, please contact us at privacy@joinaxe.ai.

Data Subject rights

The European Union's General Data Protection Regulation (GDPR) and other countries' privacy laws provide certain rights for data subjects. Data Subject rights under GDPR include the following:

• Right to be informed
• Right of access
• Right to rectification
• Right to erasure
• Right to restrict processing
• Right of data portability
• Right to object
• Rights related to automated decision making including profiling

Axe Payments Limited does not carry out automated decision-making or profiling that produces legal or similarly significant effects on individuals.

This Privacy Notice is intended to provide you with information about what personal data Axe Payments Limited collects about you and how it is used.

If you wish to confirm that Axe Payments Limited is processing your personal data, or to have access to the personal data Axe Payments Limited may have about you, please contact us.

You may also request information about: the purpose of the processing; the categories of personal data concerned; who else outside Axe Payments Limited might have received the data from Axe Payments Limited; what the source of the information was (if you didn't provide it directly to Axe Payments Limited); and how long it will be stored. You have a right to correct (rectify) the record of your personal data maintained by Axe Payments Limited if it is inaccurate. You may request that Axe Payments Limited erase that data or cease processing it, subject to certain exceptions. You may also request that Axe Payments Limited cease using your data for direct marketing purposes. In many countries, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how Axe Payments Limited processes your personal data. When technically feasible, Axe Payments Limited will, at your request, provide your personal data to you.

Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Axe Payments Limited will provide you with a date when the information will be provided. If for some reason access is denied, Axe Payments Limited will provide an explanation as to why access has been denied.

For questions or complaints concerning the processing of your personal data, you can email us at privacy@joinaxe.ai. You also have the right to lodge a complaint with the Irish Data Protection Commission (DPC), which is the lead supervisory authority for Axe Payments Limited, at https://www.dataprotection.ie. If you are located in another EU member state, you may also contact your local data protection authority.

Security of your information

Axe Payments Limited takes the security of your personal data seriously. We have implemented appropriate technical and organisational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorised disclosure, or access. These measures include:

• Encryption: data is encrypted in transit using TLS and at rest using industry-standard encryption
• Access controls: access to personal data is restricted on a least-privilege basis, with multi-factor authentication enforced for all internal systems
• Monitoring and logging: infrastructure and application activity is continuously monitored for anomalies and security events
• Vendor security assessments: all sub-processors and third-party vendors are assessed for security compliance before engagement and reviewed on an ongoing basis

Despite these safeguards, no method of electronic transmission or storage is completely secure. If you have reason to believe that your interaction with us is no longer secure, please notify us immediately at privacy@joinaxe.ai.

Enterprise clients using the Axe Payments Limited platform may refer to our Data Processing Agreement for full details of the technical and organisational security measures applicable to the processing of personal data. The DPA is available at https://www.joinaxe.ai/dpa.

Data storage and retention

Your personal data is stored by Axe Payments Limited on its servers, and on the servers of the cloud-based database management services Axe Payments Limited engages, located primarily within the European Economic Area (EEA). Where data is stored by sub-processors outside the EEA, appropriate safeguards are in place as described in the “International transfers of personal data” section above. Axe Payments Limited retains service data for the duration of the customer's business relationship with Axe Payments Limited and for a period of time thereafter, to analyse the data for Axe Payments Limited's own operations, and for historical and archiving purposes associated with Axe Payments Limited's services. In any event, customer data is not retained for longer than is required to fulfil applicable legal and tax obligations, which in Ireland is generally 6 years. Axe Payments Limited retains prospect data for no longer than 24 months from the date of last interaction, after which it is purged from Axe Payments Limited systems.

All personal data that Axe Payments Limited controls may be deleted upon verified request from Data Subjects or their authorised agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at privacy@joinaxe.ai.

Questions, concerns or complaints

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at: